2009 Jan

NOTE: The bold Year Month Date (e.g., 2009 Jan 5) headings below are the dates the filings appeared on the FERC eLibrary Docket, but not necessarily the dates the comments were actually submitted or received by FERC.

To help users find the most recently-posted comments, we display the filings by date of appearance on the Docket,not by date filed or date accessioned. FERC's eLibrary displays comments by date filed, rather than by date posted to the eLibrary Docket; therefore, newly-posted comments in FERC's online eLibrary Docket List may appear in places other than at the end of the list.

They claim emissions from the Terminal Site sources will not cause
or contribute to exceeding ambient air quality standards and will not exceed the thresholds
established for preventing the significant deterioration of air quality in the region;

They claim drinking water will not be affected;

They claim that taking on ballast water will have only a minor negative effect on local species populations, even though they're still doing studies regarding this issue;

They admit wetlands and vernal pools would be affected. They say they intend to minimize and mitigate the effects;

They claim the negative socioeconomic impacts from their project can be adequately mitigated as indicated in the study they had done by the Maine Center for
Business and Economic Research and the University of Southern Maine.

They claim, "Available existing resources are adequate to accommodate the project without harmful effects to the local economy." [Observation: This claim is specious, especially regarding Emergency Management issues. The FERC-required area Emergency Response Plan isn't completed until after FERC issues a permit to construct; thus, no one knows what the actual Emergency Management responsibilities and economic costs would be to area communities or local and state taxpayers at this time. For instance, what would be the costs of building — and the ongoing operations of — a local major burn-treatment hospital? (There is no hospital within one hour of this area that has such a facility or even enough beds for such a facility.) But, Calais LNG claims in this filing, "Local, county, and state public safety resources should
be more than sufficient."];

They claim minor impact would occur on fishing, even though they're still studying that issue. They claim LNG transits would have "no measurable impacts on fishing boats or other uses of the waterway for shipping," and "the studies of impact on local fisheries and fishing gear
determine there is no measurable impact."

They claim the aesthetic impacts of the terminal would be "acceptable." They claim, "Safety is a core commitment of Calais LNG." [Observation: And yet, they propose a terminal site and ship transit lane that cannot be made to conform with world LNG industry terminal siting best practices as published in 1997 by the Society of International Gas Tanker and Terminal Operators (SIGTTO) in "Site Selection and Design for LNG Ports and Jetties." (See LNG Terminal Siting Standards Organization for an abbreviated list of the industry's terminal siting best practices.)];

"The Coast Guard will make its own determination as to the suitability of
the waterways for the proposed Project from a safety and security standpoint, and its
determination will be reflected in a public document to be issued once the Commission and the
Coast Guard have concluded their comprehensive Environmental Impact Statement with respect
to the Project." [Observation: In other words, Calais LNG cannot claim waterway suitability or that the route and terminal location can be secured. Security along the transit route cannot be assured since Canada prohibits LNG transits and will not cooperate in security of the proposed LNG carriers through Canadian waters. Just as the United States has the authority to determine suitability of a US waterway for LNG transit (and the authority to deny LNG transits), Canada likewise has the sovereign authority to make those same decisions for its own waters. Canada has already made that determination, with a decision that is in keeping with world LNG industry terminal siting standards— the waterway is not suitable and Canada is prohibiting LNG transits into Passamaquoddy Bay.];

They claim "a compelling need for natural gas in the New England market area." They state, "The overarching
need for competitively priced [emphasis added] natural gas to meet peak demands in New England has three
principal bases: (1) New England has the most expensive natural gas in the country, which
translates into higher electricity prices; (2) reliable natural gas supply is constrained by pipeline
congestion; and (3) New England lacks sufficient local natural gas production and storage." [Observations: Yes, there's a need, but that needis already being met into the future. Also, LNG is more expensive than domestic natural gas. In other words, Calais LNG wants to increase the price of natural gas (or, at least, to keep it high) in New England, with Calais LNG reaping the profit from that higher price to be paid by New England residents and businesses.];

Calais LNG also claims, "floating storage and regasification units are not feasible in many of the rough waters of
Northern New England, including the Gulf of Maine, Grand Manan, and the Bay of Fundy." [Observations: This is a case of "blowing smoke" to obscure reality. Offshore regasification (based on technology used successfully for decades by the oil industry in the North Sea and elsewhere) already in place in the Gulf of Mexico (Gulf Gateway Deep Water Port) have shown that even Hurricane Katrina didn't prevent regasification of an entire ship's LNG cargo during that storm. Calais LNG ignores the two offshore LNG receiving facilites — one already in operation (Northeast Gateway Deepwater Port), the other (Neptune LNG Deepwater Port) to be completed by the end of this year — in the Gulf of Maine off Gloucester, Massachusetts. Offshore submerged-buoy technology more easily handles rough seas than does shoreside receiving technology, and with less risk. Further, LNG storage is more flexible (can be moved to locations with greater need) when on ships designed for that purpose, as is used and advocated by Excelerate Energy, masterminds of the Gulf Gateway and Northeast Gateway LNG facilities]; and, finally

They claim, "the extensive assessments undertaken to date indicate that the Project is
unlikely to have any significant additional physical or visual impact [emphasis added] on culturally or historically
significant resources in the vicinity of the Terminal Site or along the Preferred Pipeline Route." [Observation: Using the Port of Bayside as an excuse for Calais LNG approximately doubles the impact — a significant cumulative impact.]

Filed By: INDIVIDUAL [Diane Barnes, City Manager, City of Calais]Filed Date: 12/15/2008 [NOTE: Document is dated November 19, 2008, was filed with FERC on December 15, 2008, but was accessioned and posted to the Docket on January 6, 2009. It appears on the FERC Docket under December 15, 2008.]Accession No: 20090106-0279Description: Comments of Diane Barnes re the Calais LNG Project that is being proposed for Washington County under PF08-24. [Summary: Employment and conomic reasons for support.]Information:FILE LISTorImmediately Download theFERC PDF file (36.96 KB).

Filed By: INDIVIDUAL [Jim Porter, Assistant Manager, City of Calais]Filed Date: 12/15/2008 [NOTE: Document is dated December 4, 2008, was filed with FERC on December 6, 2008, but was accessioned and posted to the Docket on January 6, 2009. It appears on the FERC Docket under December 15, 2008.]Accession No: 20090106-0280Description: Comments of Kim [stet; "Jim"] Porter re Calais LNG Project under PF08-24. [Summary: Employment and economic reasons, plus "convenient availability of natural gas" for support.][Comment:The availability of natural gas has existed for years via the Maritimes & Northeast Pipeline if Calais were seriously interested in accessing it.]Information:FILE LISTorImmediately Download theFERC PDF file (46.87 KB).

Filed By: CITY OF CALAIS [Mayor Vinton Cassidy]Filed Date: 12/6/2008 [NOTE: Document is dated December 4, 2008, was filed with FERC on December 6, 2008, but was accessioned and posted to the Docket on December 15, 2008. It appears on the FERC Docket under December 15, 2008.]Accession No: 20090106-0281Description: Comments of Calais City Council re Calais LNG project under PF08-24. [Summary: He cites employment, more efficient and cleaner fuel, economic benefit, and availability of natural gas. Also, Calais will be prepared to train for and respond to any emergency incidents. They "believe in the safety of LNG."][SPB Webmaster Comments:

The net economic impact from Calais LNG would be negative, according to The Whole Bay Study;

Natural gas has been available to Calais for some years, if they had an interest in accessing it.

How could Calais know what it would cost taxpayers to train the city's Emergency Responders, since the Emergency Response Plan wouldn't be developed until after FERC were to issue a permit?

Why would the City of Calais "believe in the safety" of the proposed LNG terminal when its siting violates world LNG industry safe siting standards (per the SIGTTO publication "Site Selection and Design for LNG Ports and Jetties")? (See LNG Terminal Siting Standards Organization for an abbreviated list of those standards.]

Filed By:MAINE, STATE OF (sic; corrected by FERC on Jan 7) INDIVIDUAL [Former Maine State Senator Harold Silverman]Filed Date: 12/15/2008 [Note: This document is dated December 4, 2008, was accessioned December 15, but didn't appear on the FERC Docket until January 6, 2009. It is filed on the FERC Docket under December 15, 2009.]Accession No: 20090106-0283]Description:Maine State Senator (sic; corrected by FERC on Jan 7) Former Maine State Senator Harold L Silverman submits comments re the Calais LNG Facility under PF08-24..
[Summary:[NOTE: Harold Silverman is not a state senator, although by the way he filed his comments he seems to believe he represents the entire State of Maine. On January 7, 2009, FERC edited Silverman's "Filed By" and "Description" entries to correct Silverman's misrepresentations in the filing.]His comments relate to jobs and economy; he claims the LNG facility and LNG transport would provide a low-cost, safe, alternate source of energy. He also claims the LNG industry has spent millions on research to make LNG safe and environmentally sound. SPB Webmaster's Comment:Silverman wrongly implies that his comments are from the State of Maine. He ignores the LNG industry's own safety guidance that Calais LNG's site selection violates — the same guidance that cost the industry some of the dollars that Silverman mentions.]Information:FILE LISTorImmediately Download theFERC PDF file (75.74 KB).

Filed By: ROOSEVELT CAMPOBELLO INTERNATIONAL PARK COMMISSIONFiled Date: 12/15/2008 [Note: This record did not appear on the FERC Docket until January 6, 2009. It is filed in the Docket under December 15, 2008.]Accession No: 20090106-0282Description: Roosevelt Campobello International Park Commission submits comments re Calais LNG Project under PF08-24..
[Summary:The Park expresses grave concerns regarding this project, particularly about degradation of air quality and potential water pollution. Concerns are expressed re LNG transport safety and risk of potential death, damage, and injury due to thermal impacts on Campobello Island, residents, Park visitors, and the Park's historic structures; re the lack of Emergency Response preparedness and infrastructure; re the cascading negative economic impact the LNG project would bring to area toursim; and re interruptions to essential ferry transport. The Park also mentions the international treaty of binidnig responsibility to protect the Park.

Filed By: INDIVIDUAL [Former US Assistant Surgeon General Brian W. Flynn]Filed Date: 12/15/2008 [Note: This filing was submitted by hand at the December 4, 2008, FERC Scoping Session, was not filed by FERC until December 15, and wasn't accessioned and did not appear on the FERC Docket until January 6, 2009. It appears on the Docket under December 15, 2008.]Accession No: 20090106-0284Description: Comments of RADM Brian W Flynn re Calais LNG Project under PF08-24.
[Summary:Considerable detail is provided on the requirement for emergency preparedness, and how the Calais LNG project is exceptionally complicated by the need for international emergency cooperation and preparedness. Two papers are presented on health care in the case of a mass-casualty LNG incident. Details are provided about scope of injuries to be anticipated, and the medical response requirements for such an event. The closest Level 1 Trauma Center (with only 12 burn beds) in Maine is in Portland, with the closest New Brunswick Level 1 Trauma Center being in Saint John. Flynn asks how FERC weighs adequacy of state and local emergency capacity in the permit decision process. Many other cogent questions are asked about the FERC decisionmaking process as it relates to emergency response and treatment that would be required on both sides of the international border.]Information:FILE LISTorImmediately Download theFERC PDF file (618.28 KB).

Filed By: THREE NATION ALLIANCE [SAVE PASSAMAQUODDY BAY]Filed Date: 12/13/2008 [Note: This document was prepared on December 3, 2008, and manually submitted on December 4, 2008, to FERC personnel at the Scoping Session in Calais; however, it was filed by FERC on December 13, and not accessioned or posted to the Docket until January 6, 2009. It appears on the FERC Docket under December 13, 2008.]Accession No: 20090106-0286Description: Three Nation Alliance submits comments on the scoping stage of the Calais LNG Project Company, LLC import and storage terminal etc under PF08-24.
[Summary:The LNG transit route for Calais LNG would be identical to the previous two are LNG proposals, with the additional transit up the narrow St. Croix River. Canada prohibits LNG transits into Passamaquoddy Bay and up the St. Croix River. The project is incompatible with existing uses of the waterway, including rights of Passamaquoddy Tribal fishermen. Numerous negative impacts would impinge on the environment and area conservation areas and parks as well as on residents' quality of life.]Information:FILE LISTorImmediately Download theFERC PDF file (15.50 KB).

Filed By: SAVE PASSAMAQUODDY BAYFiled Date: 12/15/2008 [Note: This filing was manually submitted on December 4, 2008, to FERC personnel at the Scoping Session in Calais; however, it was filed by FERC on December 15, and not accessioned or posted to the Docket until January 6, 2009. It appears on the FERC Docket under December 15, 2008.]Accession No: 20090106-0285Description: Save Passamaquoddy Bay submits comments re a Report on Potential Economic and Fiscal Impacts of LNG Terminals on the Whole Passamaquoddy Bay under PF08-24.
[Summary:This submission consists of what is commonly known as "The Whole Bay Study."]Information:FILE LISTorImmediately Download theFERC PDF file (6.68 MB).

Filed By: CALAIS LNGFiled Date: 1/08/2009Accession No: 20090113-0287Description: Calais LNG Project Company LLC submits Draft Resource Report 5 (Socioeconomic Conditions and Impacts) under PF08-24.
[Summary:Calais LNG states no adverse environmental justice impacts are anticipated, nor are adverse impacts expected due to the influx of a large number of workers during construction. LNG ship transits from entrancing near Head Harbour would be 23 nautical miles (26.5 statute miles/42.6 kilometers). They also claim the pier would be "less than 1,000 ft from mean low water." They claim a wide margin of citizens of Washington County support the project, but provide no empirical evidence. The City of Calais doesn't anticipate needing to increase its emergency response capability. Maritimes & Northeast Pipeline will have adequate capacity to carry Calais LNG's output.]

[SPB Webmaster's Comments:

Calais LNG used the IMPLAN economic impact model to make its predictions — the same flawed method used by Downeast LNG. Darius Irani, the featured speaker whom Downeast LNG's Dean Girdis paid to make a presentation at a Sunrise County Economic Council Economic Summit on LNG in Machias, agreed that IMPLAN was a "poor man's" method of economic analysis, and that it relied on dated and flawed assumptions;

Calais LNG ignores The Whole Bay Study that predicts a net negative economic impact on the area from an LNG terminal.

The indicated total pier length will probably be longer than 1,000 feet, in apparent violation of Maine littoral rights;

Calais LNG provides no basis for the claim that a majority of Washington County citizens support the project. The vast majority of the population — the majority being citizens of Canadia — surrounding Passamaquoddy Bay oppose all LNG projects in the bay;

Calais and all communities along the LNG transit route would need to increase their emergency response capability, but costs for that increase are not known until after FERC issues a permit to construct; thus, Calais and all other affected communities would be caught with unexpected expenses and higher demands on taxpayers;